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We also disagree with respondent’s contention that property
with a relatively long economic useful life is necessarily
designed to remain permanently in place. In Estate of Morgan v.
Commissioner, 52 T.C. at 481, 483, where the floating docks had
an estimated useful life of 20 years, or longer with periodic
part replacements, we concluded that the floating docks were not
inherently permanent. Similarly, in Film N’ Photos, Inc. v.
Commissioner, T.C. Memo. 1978-162, the photo merchandising huts
at issue were not inherently permanent, even though they could
remain at the same location for 20 years or more and had a useful
life of 50 years or more. See also Fox Photo, Inc. v.
Commissioner, supra (1-hour photo labs had an estimated useful
life of 50 years but were not designed to remain permanently in
place).
Respondent further asserts that the internal roof support
columns in the tanks reflect permanence. When relocating an
intact tank with internal roof support columns, internal bracing
is required to support the tank floor and roof. The bracing is
not part of the tank’s design and must be added to a tank before
moving it. However, when using the dismantling and
reconstruction procedures for relocating tanks in API Standard
653, the internal bracing is not necessary.
In Fox Photo, Inc. v. Commissioner, supra, the 1-hour photo
labs’ steel frames were reinforced beyond regular support
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